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FCC
DTV Consumer Education
Frequently Asked Questions (FAQ)
Below
are answers to some frequently asked questions about
the FCC’s DTV Consumer Education requirements.
The first part of this FAQ addresses the rules generally;
the second part discusses the PBS-produced PSAs.
General Questions about the FCC’s Rules
1.
What are on the on-air requirements of the FCC’s
DTV Consumer Education rules?
The FCC requires stations to provide on-air information
about the DTV transition, in accordance with one of
three options. A description of those options, which
was previously provided to member stations, is attached
for ease of reference. We also highlight below the requirements
of Option Three, the APTS plan, which is available solely
to noncommercial stations and does not require airing
of crawls, snipes and tickers (“CSTs”):
Effective Date until April 30, 2008: air spots for at
least 60 seconds per day; spots should be aired in variable
timeslots, including at least 7.5 minutes per month
in the 6 pm – 12 am timeslot.
May 1, 2008 – Oct. 31, 2008: air spots for at
least 120 seconds per day; spots should be aired in
variable timeslots, including at least 15 minutes per
month in the 6 pm – 12 am timeslot.
Nov. 1, 2008 – March 31, 2009: air spots for at
least 180 seconds per day; spots should be aired in
variable timeslots, including 22.5 minutes per month
in the 6 pm – 12 am timeslot.
Informational Program: Once prior to Feb. 17, 2009,
each station must also air a 30-minute informational
program on the DTV transition. That program must air
between 8 am – 11:35 pm.
2.
When must stations file Form 388 with the FCC?
Form 388 must be filed by the tenth day following the
end of each calendar quarter (i.e., April 10, July 10,
October 10, and January 10). The first Form 388 is due
on April 10, 2008.
3.
What time period is covered by the Form 388?
The first filing, due April 10, will cover the period
beginning on the date on which the Federal Register
publishes notice that the Office of Management and Budget
has approved the new form. Because that publication
is not expected to occur until later this week, and
the quarter ends on Monday, March 31, the first filing
(due April 10) will cover only a short period of time.
Subsequently filed forms will cover the entire calendar
quarter (e.g., the filing for the Second Quarter of
2008, due July 10, will cover the period April 1 thru
June 30).
4.
How must stations file Form 388 with the FCC?
Form 388 must be submitted electronically to the FCC
in Docket Number 07-148. To submit the form, go to the
following web site: http://www.fcc.gov/cgb/ecfs/. Under
the heading “ECFS Main Links” on the right-hand
side of the web page, click on the link “Submit
a Filing” and then fill in the Cover Sheet with
the proceeding number (“07-148”), station
contact information, and the document type (“Report”).
To submit Form 388 to the FCC, use the box labeled “Send
Comment Files to the FCC (Attachments)” and navigate
locally to a saved electronic version of your station’s
Form 388, select the file type (e.g., Word, PDF, etc.),
and then click on “Send Attached File to FCC.”
To complete the filing, you must confirm that you wish
to submit the form to the FCC on the next screen. After
submitting the form, you will see a confirmation screen
which should be printed and kept with the completed
Form 388.
5.
Must Form 388 be placed in a station’s public
inspection file and posted on a station’s website?
Form 388 is required to be retained in a station’s
public inspection file for one year. In addition, the
form is required to be posted a station’s website
if the station maintains a website. Stations must publicize
in an appropriate manner the existence and location
of these reports.
6. When are stations required to begin providing on-air
DTV education?
A station must begin airing PSAs (and CSTs, if selecting
Option One or Two) on the date that the FCC’s
new DTV consumer education rules go into effect. The
new rules will go into effect on the day OMB approval
of the rules is published in the Federal Register, which
has not yet occurred but is anticipated later this week.
7. When does the requirement to provide on-air DTV education
end? A
station must air PSAs (and CSTs, if selecting Option
One or Two) until March 31, 2009. In addition, after
March 31, 2009, any station that has filed a request
for an extension to serve its full digital service area
or is operating under such an extension must continue
its education campaign until the request is withdrawn
or denied or, if granted, until it expires.
8.
On which channels must a station provide on-air DTV
education?
Stations must provide on-air DTV education on the analog
channel (until that channel ends, presumably on Feb.
17, 2009) and primary digital channel. The DTV-education
requirements do not apply to multicast channels.
9.
Why does the noncommercial Section C of the Form 388
ask about crawls? Aren’t noncommercial stations
selecting the Option Three (APTS plan) exempt from airing
crawls?
When the FCC released its DTV Education Order on March
3, it erroneously included a reference to crawls in
the noncommercial Section C of the Form 388. The FCC
has since issued an erratum, and the official Form 388
will not include a reference to crawls in Section C.
Stations selecting Option Three (APTS plan) are not
required to air crawls.
10.
Do we have to fill out Section D of the Form 388?
Yes. Section D of the Form 388 asks stations (both noncommercial
and commercial) to report on additional, voluntary measures
taken to promote the DTV transition.
11.
Can a station change the DTV consumer education option
it has selected?
A station will select its DTV consumer education option
on its first Form 388 (due April 10, 2008). Once a station
has elected an option on Form 388, it must continue
to meet the requirements of the option until March 31,
2009 (or longer if a station has been granted an extension
beyond March 31, 2009 to serve less than its full authorized
service area). A station may not change its option after
it has selected one and reported its selection on Form
388.
12.
In addition to the required PSAs on the DTV transition,
should we continue to air PSAs about subjects other
than the DTV transition? The FCC has emphasized its
expectation that stations will air the required DTV
PSAs “in addition to, and not in lieu of, PSAs
on other issues of importance to their local communities.”
Questions about PBS-produced spots on the DTV Transition
13.
Can stations count PSAs produced and distributed by
PBS towards their educational requirements?
Stations may use, and count towards their compliance,
PSAs provided by PBS. As required by the FCC’s
rules, the PBS PSAs are closed captioned.
14.
What is the length of each PSA produced and distributed
by PBS?
PBS is delivering both a 30-second and 60-second PSA.
For Options Three (APTS Plan), the FCC sets the aggregate
amount of seconds that must be aired per day –
it does not define the length of an individual spot.
Thus, stations may use a combination of PBS spots, so
long as they meet the aggregate number of seconds per
day, minimum number of minutes per month in the 6pm
– 12am timeslot, and general requirement to air
the spots in variable timeslots.
15.
Is PBS including DTV education spots in the HD feed
during breaks in regular programming?
Yes, PBS is currently running 30-second DTV spots two
times per day on the PBS HD Channel to meet the daily
minimums of Option Three (APTS Plan). PBS will generate
a report of when the spots are fed on our packaged channels
(Schedules X and XP and the HD Channel) that stations
may include in their station FCC reports.
16.
Options Two (NAB Plan) and Three (APTS Plan) require
each station to air one, 30-minute informational program
before Feb. 17, 2009. Will PBS provide such a program?
Yes. PBS will produce and distribute a 30-minute informational
program on the DTV transition. We are currently exploring
production options and will keep member stations apprised
of progress and timing.
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